PRIVACY AND PERSONAL DATA PROTECTION POLICY

(version effective from 01.08.2026)

The management of the website located on the Internet at: https://machinery.pts.ua/, the sale of goods and the provision of services listed on the Site, are carried out by the Limited Liability Company “TRADING AND MANUFACTURING ENTERPRISE PROMTEHSERVIS” (USREOU code 41227462) (hereinafter — the Owner).

The Privacy and Personal Data Protection Policy (hereinafter — the Privacy Policy) applies to all information that the Owner of the Site or the Site Administration receives about the Visitor / Customer during the use of the Site or the receipt of services, programs and products, as well as the ordering of goods offered on the Site.

This Privacy Policy establishes the procedure by which the Owner processes personal data, the types of personal data collected, the purpose of using such personal data, the Owner’s interaction with third parties, the security measures for the protection of personal data, the conditions of access to personal data, as well as the contact information for the Customer regarding obtaining access to, amending, blocking or deleting personal data and raising any questions that the Visitor / Customer may have concerning personal data protection practices.

1. KEY DEFINITIONS

1.1. Site — the website that belongs to the Owner and has the Internet address https://machinery.pts.ua/ and is managed by the Site Administration.

1.2. Site Administration — the persons authorised by the Owner to manage the Site, who organise and carry out the processing of personal data in accordance with the purpose determined by the Owner, the composition of the personal data subject to processing, and the actions or operations performed with the personal data.

1.3. User Agreement / Terms of Use of the Site — a document published on the Site on the Internet, which governs the relations between Customers, Visitors of the Site and the Owner in the process of providing services and ordering goods. The User Agreement is a public offer agreement and an adhesion agreement.

1.4. Visitor — any natural person who has access to the Site and uses the Site by means of the Internet.

1.5. Customer — a Visitor who has accepted the User Agreement and placed an order on the Site (including by sending an enquiry through the contact form), and who is the recipient (consumer) of services and goods under the User Agreement.

1.6. Personal Data — information or a set of information about a natural person who is identified or can be specifically identified (a personal data subject).

1.7. Services — the services provided by the Owner of the Site, the list, type, composition, procedure of provision and other characteristics of which are specified in the User Agreement and posted on the Site.

1.8. Goods — the products offered for sale by the Owner of the Site and / or information about which is posted on the Site, including special machinery, attachments, spare parts, components and consumables for special machinery.

1.9. Processing of Personal Data — any action (operation) or set of actions (operations) performed with personal data with or without the use of automation tools, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), blocking, deletion and destruction of personal data.

1.10. Confidentiality of Personal Data — a mandatory requirement for the Site Administration or any other person who has obtained access to personal data not to allow their dissemination without the consent of the personal data subject or another lawful ground.

1.11. Other terms not defined in this section may be used in this Privacy Policy; in such a case, the interpretation of the terminology used in the Privacy Policy shall be carried out in accordance with the text of this Privacy Policy. In the absence of an unambiguous interpretation of the terminology in the text of the Privacy Policy, the terms shall be interpreted: firstly — in accordance with the materials posted on the Site; secondly — in accordance with the interpretation and definition of terms established on the Internet.

2. GENERAL PROVISIONS

2.1. The use of this Site by the Visitor / Customer means the automatic and full consent of the Visitor / Customer to this Privacy Policy and to the terms of processing of personal data.

2.2. Consent to the processing of personal data is given by the Visitor / Customer by performing a conscious active action — completing and submitting the contact form on the Site or independently communicating their data in correspondence with the Owner — which evidences the voluntary expression of the person’s will to grant permission for the processing of their personal data in accordance with the purpose of processing determined by this Privacy Policy.

2.3. If the Visitor does not agree with the terms of the Privacy Policy, the Visitor is obliged to stop using the Site and leave it immediately.

2.4. This Privacy Policy applies to the Site, as well as to the Services and Goods presented on the Site and provided under the User Agreement.

2.5. The Site does not control and is not responsible for third-party websites to which the Visitor may navigate via links available on the Site.

2.6. The Site Administration does not verify the accuracy of the personal data provided by the Visitor / Customer.

2.7. The Site Administration is the controller of the personal data of Visitors / Customers of the Services and Goods. The controller of personal data is the person who determines for what purpose and in what manner personal data are to be collected.

3. SUBJECT MATTER OF THE PRIVACY POLICY

3.1. The Privacy Policy establishes the obligations of the Site Administration regarding non-disclosure and ensuring the regime of protection of the confidentiality of personal data which the Visitor / Customer provides to the Site Administration when completing applications, contact forms, leaving other data on the Site, or when interacting with the Site.

3.2. Personal data permitted for processing under this Privacy Policy are provided by the Customer by completing certain forms on the Site or in free form, and may include the following information:

3.2.1. full name;

3.2.2. contact telephone number;

3.2.3. the name of the Customer’s company;

3.2.4. the content of the comment (message), including any other data that the Visitor / Customer has voluntarily provided.

3.3. There is no field for entering an email address in the contact form on the Site, and email addresses are not collected through the contact form. The email address and other data of the Visitor / Customer are processed only if the Visitor / Customer has communicated them independently by contacting the Owner by email.

3.4. In addition to the data provided for by the terms of this Privacy Policy, the Site Administration reserves the right to automatically collect the following data in the course of the use of the Site or its individual pages by the Customer / Visitor:

3.4.1. the IP address of the computing device (computer, telephone, tablet, etc.) at the time of making an enquiry when the contact form is submitted, which is also processed by the Site’s security system;

3.4.2. information about the device and browser (user-agent), including the name and version of the browser, the operating system, and language settings;

3.4.3. technical (functional) cookie data stored in the browser;

3.4.4. the time of access to the Site and technical logs of visits to the pages of the Site — solely within the operation of the Site’s security system;

3.4.5. the approximate determination of the country by IP address — solely within the operation of the Site’s security system. Precise geolocation information (GPS location) is not collected.

3.5. The Site uses exclusively technical and functional cookies necessary to ensure the operation of the Site, namely: pll_language (storing the selected language of the Site); wfwaf-authcookie-*, wf_* (service cookies of the Site’s security system); wordpress_*, wp-settings-*, wordpress_logged_in_* (session cookies used mainly for authorised users — the Owner’s employees). Analytical, advertising and marketing cookies are not used on the Site, and web analytics systems are not installed. Disabling the collection of cookies by the Visitor may result in the inability to access parts of the Site or in the incorrect operation of some of its functions.

3.6. The Site collects the confidential data provided for by the terms of this Privacy Policy, including for the purpose of detecting and resolving technical problems of the Site and ensuring the information security of the Site (web application firewall, malicious code scanning, protection against password brute-forcing, blocking of malicious IP addresses). Behavioural tracking of Visitors / Customers and the processing of data for analytical, statistical and marketing (advertising) purposes are not carried out.

3.7. Any other personal or confidential information not stipulated above is subject to secure storage and non-dissemination, except in the cases provided for by the terms of this Privacy Policy.

3.8. The Site Administration collects information and Personal Data solely in cases where:

3.8.1. the Visitor / Customer uses the Site;

3.8.2. the Visitor / Customer voluntarily completes and submits the contact form on the Site;

3.8.3. the Visitor / Customer independently contacts the Owner by email.

3.9. The Site Administration does not collect any information the processing of which is subject to specific requirements established by law, such as information about racial or ethnic origin, political, religious or ideological beliefs, membership of political parties and trade unions, criminal conviction for the commission of an offence or criminal sentencing, as well as data concerning health, sexual life, or biometric or genetic data. Payment card data are not collected or stored: the Site does not accept online payments and has no online sales, account creation, subscription or social media registration functionality.

3.10. The Customer / Visitor may transmit information and Personal Data via the Internet by:

3.10.1. sending a letter by email;

3.10.2. using the Site;

3.10.3. completing and submitting the contact form on the Site.

3.11. The transfer of data through the Site is carried out using a secure connection (HTTPS protocol / SSL certificate).

4. RESTRICTIONS

4.1. By placing an order (sending an enquiry) on the Site, the Visitor / Customer confirms that they have reached the age that allows them to enter into contracts independently.

4.2. Where the Site Administration asks the Visitor / Customer to give consent to the processing of personal data, they may do so independently.

4.3. If the Visitor / Customer has doubts as to whether they may independently give consent to the processing of personal data, they must contact the authorised personal data protection body.

4.4. The Site Administration may request the Customer to provide additional documents or to undergo additional procedures in order to verify that they have the right to give consent to the processing of personal data independently. If the Site Administration has reasonable doubts as to the age of the Customer, it may also contact their parents or guardians in order to obtain consent or approval for the Processing of personal data, if the Customer has not reached the relevant age. For the period of clarifying the circumstances or obtaining consent or approval from the parents or guardians, the Site Administration may temporarily restrict the processing of such Customer’s personal data.

5. PURPOSES OF DATA COLLECTION

5.1. The Site Administration may use the Customer’s personal data solely for the purposes of:

5.1.1. Processing enquiries sent through the form on the Site, including identifying the person who made contact in order to place an order and / or accede to the User Agreement.

5.1.2. Establishing feedback with the Visitor / Customer at the telephone number provided, including sending messages and requests concerning the use of the Site, the provision of Services, the supply of Goods, the processing of requests and applications, as well as further communication regarding the enquiry.

5.1.3. Providing the Visitor / Customer with information about the Owner’s Services and Goods, providing Services or supplying Goods as defined by the User Agreement.

5.1.4. Notifying the Customer of the status of processing of their enquiry or order for a Service / Goods.

5.1.5. Providing the Customer with effective client and technical support in the event of problems related to the use of the Site.

5.1.6. Ensuring the information security of the Site and preventing fraud and cyberattacks, including by processing IP addresses and technical data by means of the Site’s security system and the approximate determination of the country by IP address.

5.1.7. Complying with the requirements of the applicable legislation of Ukraine, including the lawful requirements of authorised state bodies.

5.2. The processing of personal data is carried out solely for the purposes determined by the terms of this Privacy Policy.

6. DATA STORAGE

6.1. The Site Administration stores the Personal Data of the Visitor / Customer for the period necessary for the Site Administration to achieve the purpose of processing specified in this Privacy Policy, but no longer than is necessary for such purpose. Enquiries sent through the contact form are stored until they are deleted by the Site Administration or until the Visitor / Customer submits a request for the deletion of Personal Data, whichever occurs first.

6.2. The Personal Data of the Visitor / Customer are stored:

6.2.1. in the Site’s database on the servers of the hosting provider — the Limited Liability Company “Hosting Ukraine” (ukraine.com.ua; P.O. Box 65, Kyiv, 04112, Ukraine). The servers are located within the territory of Ukraine;

6.2.2. in the form of duplicates of enquiries — in a secure chat of the Telegram messaging service (Telegram cloud servers), access to which is held solely by the Owner’s authorised employees.

6.3. Data storage may be carried out by another third party (processor) performing certain actions on behalf of the Site Administration, solely within the limits determined by this Privacy Policy. If the Site Administration no longer requires certain data about the Visitor / Customer and such data need not be retained in accordance with the requirements of the law, it will delete them or store them in a manner that makes the identification of the Visitor / Customer impossible.

7. PROCEDURE AND METHODS OF DATA PROCESSING

7.1. The processing of the Visitor’s / Customer’s personal data is carried out for the period determined by clause 6.1 of this Privacy Policy, by any lawful means, including in personal data information systems with or without the use of automation tools.

7.2. The Personal Data of the Visitor / Customer are transferred to third parties (processors and recipients) solely to the extent necessary to achieve the purpose of processing, namely:

7.2.1. to the Telegram messaging service — the content of the enquiry sent through the contact form (name, telephone number, company name, comment) is transferred, for the purpose of the prompt handling of enquiries by the Owner’s authorised employees;

7.2.2. to the hosting provider LLC “Hosting Ukraine” — as the infrastructure supplier that technically ensures the storage of the Site’s database;

7.2.3. to Defiant Inc. (the developer of the Wordfence security system) — IP addresses may be transferred solely within the operation of the Site’s security system.

7.3. The transfer of personal data to the Telegram service and to Defiant Inc. may constitute a cross-border transfer of personal data. Such transfer is carried out in compliance with the requirements of Article 29 of the Law of Ukraine “On Personal Data Protection”, in particular on the basis of the unambiguous consent of the personal data subject to such transfer, which is given by submitting the contact form after having reviewed this Privacy Policy.

7.4. The Personal Data of the Visitor / Customer may be transferred to authorised state and judicial bodies only where there are lawful grounds, in the manner established by the legislation of Ukraine.

7.5. In the event of the loss or disclosure of personal data, the Site Administration shall inform the Customer of the loss or disclosure of the personal data by any means available to it.

7.6. The Site Administration takes the necessary organisational and technical measures to protect personal information from unlawful or accidental access, destruction, alteration, blocking, copying and dissemination, as well as from other unlawful actions of third parties, in particular: the use of a secure HTTPS / SSL connection; the use of the Site’s security system (web application firewall, malicious code scanning, protection of logins against password brute-forcing, blocking of malicious IP addresses); the differentiation of access by login and password; granting access to the Site’s administrative panel and to the enquiry-handling chat solely to the Owner’s authorised employees.

7.7. The Site Administration, together with the Customer, takes all necessary measures to prevent losses or other adverse consequences caused by the loss or disclosure of the Customer’s personal data.

8. OBLIGATIONS

8.1. The Site Administration is obliged to:

8.1.1. Use any information received solely for the purposes specified in this Privacy Policy.

8.1.2. Ensure the secrecy and safekeeping of Personal information.

8.1.3. Not disclose, without the prior written consent of the Customer, and not sell, exchange, publish or disclose by other possible means the Customer’s transferred personal data, except under the conditions established by this Privacy Policy.

8.1.4. Take precautions to protect the confidentiality of the Customer’s / Visitor’s personal data in accordance with the procedure ordinarily used to protect information of this kind in existing business practice.

8.1.5. Block the personal data relating to the relevant Customer / Visitor from the moment of an application or request by the Customer / Visitor, or their legal representative, or the body authorised to protect the rights of personal data subjects, for the period of verification, in the event that inaccurate personal data or unlawful actions are detected.

8.2. The Customer / Visitor is obliged to:

8.2.1. Provide correct and truthful information about personal data necessary for using the Site and receiving Services and ordering Goods.

8.2.2. Update or supplement the personal data information provided in the event of a change in such information.

8.2.3. Take measures to protect access to their confidential data stored on the Site.

9. LIABILITY

9.1. The Site Administration, if it has failed to fulfil its obligations, shall be liable for the losses incurred by the Customer / Visitor in connection with the unlawful use of personal data in accordance with the applicable legislation of Ukraine, except in the cases provided for by the terms of this Privacy Policy.

9.2. In the event of the loss or disclosure of Personal information, the Site Administration shall not be liable if such information:

9.2.1. Became or was public at the time of the loss or disclosure.

9.2.2. Was received from a third party before it was received by the Site Administration.

9.2.3. Was disclosed with the consent of the Customer / Visitor.

9.3. In all relations not provided for by this clause, the Site Administration shall be liable in accordance with the applicable legislation of Ukraine.

10. DISPUTE RESOLUTION

10.1. The Visitor / Customer and the Site Administration shall resolve all disputes and disagreements arising out of the relations covered by this Privacy Policy through negotiations.

10.2. If no agreement is reached, the dispute shall be referred for consideration to the judicial bodies at the location of the defendant, in accordance with the applicable procedural legislation of Ukraine.

11. FINAL PROVISIONS

11.1. The Site Administration has the right to make changes to this Privacy Policy without the consent of, or notice to, the Visitor / Customer. The current version of the Privacy Policy is permanently available on the Site.

11.2. A new Privacy Policy enters into force from the moment of its publication on the Site, unless otherwise provided by the new version of the Privacy Policy.

11.3. This Privacy Policy is published on the Site at the Internet address https://machinery.pts.ua/.

11.4. All suggestions or questions regarding this Privacy Policy should be sent to the following email address: info@pts.ua.

11.5. This Privacy Policy complies with the requirements of the legislation of Ukraine on personal data protection and contains detailed information about the data collected, the purposes and methods of their collection, processing, use and protection.

12. COMPANY DETAILS

Limited Liability Company “TRADING AND MANUFACTURING ENTERPRISE PROMTEHSERVIS”

USREOU code 41227462

Address: 12 Yakutska Street, Kyiv, 03134, Ukraine

Email: info@pts.ua

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